OPINION.
LEMIRE, Judge:
The respondent has determined a deficiency in petitioner's income tax for 1943 in the amount of $422.20. The petitioner claims an overpayment of $46,864 in his tax for that year. The deficiency results from the disallowance of the deduction of real estate taxes which had accrued prior to the date of petitioner's purchase of property. The claim for refund, which has been disallowed in full by the respondent, involves the petitioner...
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